Implementing New FAR Requirements

 
This section will address the potential benefits and the challenges your organization is facing in implementing the new and proposed FAR requirements.

- Since December 2007, FAR Subpart 3.10 (Contractor Code of Business Ethics and Conduct) has required certain contractors to set up and follow written codes of business ethics and conduct. The FAR allows for flexibility and where appropriate, contractor discretion by providing certain exemptions for small businesses.

- As a follow-on, FAR Case 2007-006 was issued as a proposed rule in a November 2007 Federal Register to amend the FAR to require that companies holding certain types of contracts disclose suspected violations of federal criminal law in connection with the award or performance of contracts, or face suspension or debarment. This case proposes several additional changes to the FAR requirements, including full cooperation with government agencies responsible for audit, investigation, or corrective actions; and the requirement for a code of business ethics and conduct, business ethics awareness and compliance programs, and internal control system to be applicable to contracts performed outside the United States. See the proposed changes published in the Federal Register at 72 Fed. Reg. 64019 (proposed Nov. 14, 2007) and 73 Fed. Reg. 28407 (proposed May 16, 2008).
 

66.
What challenges does your organization face in implementing the FAR Subpart 3.10 requirements that have been effective since December 2007?

67.
What strategies has your organization put in place to help meet/overcome the challenges in implementing FAR Subpart 3.10?

68.
In your opinion, what are the benefits of implementing the FAR Subpart 3.10 requirements?

69.
At what point is your organization in implementing the FAR Subpart 3.10 requirements?
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